Over the past few months, SFLC.in has engaged in an empirical analysis backed by research driven data on the Grievance Appellate Committee (GAC), an online dispute resolution mechanism. The entire appeal process, from filing to decision, is in digital mode. Our experience with the GAC has shown that it is a unique quasi-judicial platform that provides quick resolution, ease of appealing, and binding decisions. In Part III of this series, we will analyse our appeals on violent content on platforms, and the insights we have received from our experiences.
SFLC.in collaborated with the Center for the Study of Organized Hate (CSOH) to take action on certain violent content being platformed on Instagram. CSOH approached us with their Report titled Streaming Violence: How Instagram Fuels Cow Vigilantism in India, where they analyzed the use of Instagram by cow vigilantes to promote extremist content, glorify anti-minority violence, and fundraise in violation of Instagram’s community guidelines. As part of our discussion, SFLC.in decided to leverage the GAC mechanism to make platforms more accountable, specifically with respect to videos showing and glorifying videos of violence, hate speech and gore.
The methodology we followed was:
1. Identifying the most egregious videos of violence
We identified the videos that fell squarely under the tag of violence, under the “violence, hate, and exploitation” tag on Meta. None of the posts or videos reported by CSOH at the time they approached SFLC.in were taken down.
2. Reporting the videos/reels on Meta platforms
The first step to initiate proceedings was to report the harmful content on Instagram. The tag was “violence, hate, and exploitation”. Once content was reported, we waited for the platform to take action. Since the reels we reported were not taken down by Meta, we continued with the established procedure under the IT Rules, 2021, and approached Instagram’s Grievance Officer,
3. Grievance Officer
We reached out to the Grievance Officers at Instagram. A total of 100 posts were reported, some by CSOH and some by SFLC.in, since Meta provided a separate avenue for reporting by lawyers on behalf of their clients. Since we were dissatisfied with their intervention, we appealed to the Grievance Appellate Committee.
4. GAC
Within 30 days of the receipt of a response from the Grievance Officer, we filed an appeal with the GAC.
GAC Appeal Body
Subject / Keyword / Tag / Specific provision in the law (Max 100 Characters)* (if you can specify the specific clause in the Act/Rules, please enter the provisions for expedite disposal of your appeal)
Instagram, Rule 3(2), Violations of Terms of Use, IT Rules 2021, Violence, Graphic Content
Brief of Complaint (Max 1000 Characters)*
I have seen graphic content on my Instagram account of violence, gore, and hate speech. This content was uploaded in the form of a (Post/Reel) by an account with the handle (______). This content is not only deeply disturbing to watch, but it is widespread and prevalent. I have tried to report the content on the Instagram platform, but it has not been taken down. I then contacted the Grievance Officer of the platform on (______date____), but I did not receive a positive response. Content that promotes violence, bloodshed, and glorifies crime and mob justice is not only illegal but also a violation of the Terms of Use of the Instagram platform. It is also dangerous that such content is blatantly platformed and not actioned, without any rationale being provided to aggrieved users.
Justification for invoking the ground for appeal (max. 250 words)*
I am preferring this appeal under rule 3A of the IT Rules 2021, as the intermediary (Instagram) has failed to resolve my grievance within the prescribed timeframe as under Rule 3(2)(i) of the IT Rules, 2021, and has not acted upon reports I have filed with the Grievance Officer.
Instagram is an intermediary that has not taken action based on illegal and per se, violative content that has been uploaded on its platform. This matter, therefore, falls squarely under the jurisdiction of the Committee.
The content being depicted in the posts that I have reported is violative of Rule 3 (b)(ii) of the IT Rules, 2021, as it is inciting violence and promoting enmity between different groups on the grounds of religion. It is further in violation of the Terms of Use of Instagram, particularly Clause 4.2- You can’t do anything unlawful, or for an illegal or unauthorised purpose. The violent content in question is, per se, unlawful and violative of Sections 114, 116 and 131 of the Bharatiya Nyaya Sanhita. Further, it violates the Community Guidelines of Instagram, particularly the Violent and Graphic Content, and Coordinating harm and promoting crime Guidelines.
In light of the fact that such per se violative content has not been taken down, and continues to be viewed and disseminated online, I believe that an appeal is appropriate.
The links are (Post Links)
Relief Sought Details (Max 500 Characters)*
I humbly request the following:
- The content I have reported is immediately taken down.
- That the pages and handles that disseminate and glorify this content are taken down by the Platform.
- Clear reasons should be provided by platforms when not taking down content that is violative of the Terms of Service of the platforms.
Outcome
We faced considerable hurdles in the process of reporting this content. Firstly, the timelines mandated for Grievance Officers were rarely followed. One reply took 90 days, triple the prescribed limit of 30 days. Following this painstaking process, we filed GAC appeals for 20 posts, in batches of 4. 3 appeals were filed by CSOH, and 1 by SFLC.in.
1. GAC Appeal 15638/2025 – 16/10/2025
The first GAC appeal filed by CSOH was rejected on the grounds that- “Meta states it is premature and not maintainable since no specific grievance officer decision was challenged, and requests the appellant to submit details via official forms to allow proper grievance handling. Grievance Appellate Committee has gone through the appeal and reply of Meta. Appellant is advised to fill the form so that Grievance Officer of Meta Platforms Inc. can address the grievance of appellant first as per IT Rules.” This was surprising, considering that as part of the evidence submitted, screenshots of the responses received from the Grievance Officer were attached.
2. GAC Appeal 16713/2025 – 11/11/2025
The second GAC appeal was rejected on the same grounds as above, that no specific grievance officer decision was challenged, again, despite evidence to the contrary being submitted.
3. GAC Appeal 16714/2025 – 28/10/2025
The third GAC appeal filed by CSOH was rejected outright, on the grounds that it was similar to the first appeal we filed. However, both the Instagram page, and the Instagram posts we challenged were different, leading to the conclusion that perhaps the GAC was relying on AI to filter out similarly worded appeals. An RTI appeal filed to inquire about the same received no concrete response and has been appealed.
4. GAC Appeal 19422/2025 – 4/12/2025
The fourth GAC appeal was filed by a lawyer at SFLC.in, representing an individual as an attorney. Meta, at the Grievance Officer level offers lawyers and representatives to file a report on behalf of someone they represent, a function that is unique amongst platforms. SFLC.in reported 5 posts, and in violation of the prescribed deadline of 15 days, a negative reply was received after 90 days. In appeal, the GAC was approached on 4/12/2025. However, a decision was received only on 6/4/2026, despite a timeline of 30 days being prescribed. However, every one of the posts reported has been taken down.
Meta claimed that the appeal was filed beyond the 30 day limit, and was therefore time-barred, failing to note that its own Grievance Officer had replied after 3 months of filing a grievance.
Of the 5 posts reported, Meta stated that it had taken appropriate action against 2, and that the remaining 3 were found to have no violations of its Community Standards.
Interestingly enough, all 5 posts have been taken down and are no longer available on Instagram.
